DISCOVER MY ROUTE PRIVACY NOTICE

DISCOVER MY ROUTE PRIVACY NOTICE

Last Updated: March 21, 2019Community Living Toronto (the “Company”, “we”, “our” or “us”) provides its customers and users (“User(s)” or “you”) with a mobile application platform and web services providing public transit information and enabling Users to plan and optimize public transportation trips (the “Services”). The Company is committed to your privacy. This Privacy Notice is intended to inform you of our collection, use, disclosure, retention, and protection of your personal information when using our Services. Our Services include our websites at www.discovermyroute.com/dmr and any additional websites owned and operated by the Company or its affiliates (the “Site(s)”), our downloadable mobile application(s) (the “App”) and related public transportation information and additional services. Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Use available at www.discovermyroute.com/terms_of_use which this Privacy Notice is incorporated thereto by reference (together, the “Terms”). Please read carefully this Privacy Notice before accessing and using our Services. By Accessing or using our service you are accepting the practices described in this Privacy Notice. If you disagree to any term provided herein, you may not access or use the Services. Please note: you are not obligated by law to provide us with any personal information.

  1. WHAT INFORMATION DO WE COLLECT ABOUT YOU?
    • First – what is personal information?
      • Personal information is individually identifiable information about a person, namely information that identifies an individual or may with reasonable efforts or together with additional information we have access to, enable the identification of an individual, or information relating to an identified or identifiable natural person which may be of private or sensitive nature. Under certain applicable laws identification of an individual also includes any information which associates an individual with a persistent identifier such as a name, an identification number, persistent cookie identifier etc.
      • Personal information does not include information that has been anonymized or aggregated so that it can no longer be used or to identify a specific natural person.
    • Next – what and when do we collect personal information?
      • We collect personal information from you and from any devices (including mobile devices) you use when you install or have the App installed (or pre-installed) on your device, or when you use or access our Services, register for an account with us, provide us with information such as your favourites and travel habits provide, us information on a web form, run searches on our Services, update or add information to your account, or through correspondence you conduct with us.More specifically we collect and use the following categories and types of information:Personal information we collect automatically when you use our Services–
    • Information collected when installing the App
      • When you install the App (or have the App installed or pre-installed) on your mobile device, the Company will set up a user account associated with that mobile device and create a User ID for you. This is a unique identifier generated by us in accordance with this Privacy Notice, which is necessary in order for us to provide you with our Services. After installation of the App, we will collect and use your information, including the User ID, Metro area and certain device information which includes your device ID or other unique identifier, advertising ID, unique device token, device type, operating system (including version and settings), as well as your device screen resolution and keyboard language, all in accordance with this Privacy Notice. We may link this information with the account created in connection with your mobile device and User ID.
    • Usage Information
      • We receive information from you when you access and use our Services, as follows: your IP address, tokens of social networks you choose to connect to your account (as described below), information regarding your clicks, views and engagement with the Services and with advertisements we may display on the Service, information concerning your traffic to and from the Services, your referral URL, our communications with you, your public transit historical searches on the Services, information about your use and your interaction with our Services, including the duration of such use; your in-app settings; and your in-app scores (“points”).
      • If you are using our Services as a developer of an online product or service connecting your online product or service to the Company Services, and have elected to open a developer account, the Company will provide you and store your Developer ID and any information with respect to the traffic directed through your online product or service.
    • Geo-Location Information and other Sensors data
      • The Company automatically collects location information such as your geo-location and your route and travel information (for example, routes and times of travel from one destination to another) in order to provide you with our Services. When using the App we collect detailed location including GPS signals and other device sensors data such as gyro/oscilloscope sent by your mobile device for which the Service is installed and activated.
      • PLEASE NOTE THAT THE COMPANY COLLECTS YOUR LOCATION DATA EVEN WHEN YOU ARE NOT USING THE APP TO PERSONLIZE THE SERVICES AND MAXIMIZE YOUR USER EXPIRIENCE AND TO DEVELOP AND ENHENCE OUR PUBLIC TRANSIT INFORMATION SERVICES. YOU MAY CHOOSE TO DISABLE AND OPT-OUT FROM THIS BACKGROUND COLLECTION OF DATA UNDER THE APP’S PRIVACY SETTINGS SCREEN.
      • The Company uses this location and sensor information to provide you with the Service and to create a detailed location history of your public transit trips.
    • Cookies & Similar Technologies
      • We perform some of the automatic collection described above through use of cookies, web beacons, unique identifiers, and similar technologies which allow us to collect information about the pages and screens you view, the links or ads you click, and other actions you take when using our Services.
      • Please take into consideration that certain portions of such above mentioned information may also be collected from your device or software, when the Services are running in the background, i.e. when they have been launched but are not actively used.
      • For more information about our use of these technologies, and how you may exercise control over them, see our Cookie Policy at http://www.discovermyroute.com/cookies_policy
      • Please keep in mind that most mobile devices and operating systems allow you to control or disable the use of certain collectable information including location services by applications, in the device’s settings menu. Personal information you give us when you use our Services – Generally, this category refers to any information, data or content you actively and voluntarily create, upload, or provide to use through our Services.
    • Account Information.
      • You may choose to set up a registered Company User account in connection with your use of the Services. When setting your Company registered User account, you may actively share with us certain personal information with us, such as email address. Another way to create an account is through connecting and using your existing social media profiles to the App, as further detailed below.
      • Note – while our Services are available to all Users, whether or not they set up a registered Company User account, we note that setting up such an account may allow you to enjoy certain features in the App that are only available to registered Company Users.
      • If you choose to use the Services without setting up a registered account, the Company will still link all of your information with a User ID generated for you, which is a unique identifier generated by us in accordance with this Privacy Notice, which is necessary in order for us to provide you with the core features of our Services.
    • Actively Provided Points of Interests (POI) Data
      • In addition, you may choose to upload specific destinations and POIs such as your home address, work address or other favourite destinations and POIs in order to personalize the Service.
      • The Company also collects information regarding public transportation lines, stations and/or routes you may have saved or searched for via the Services, User’s most-used travel and public transit routes and stations for purposes of providing the Service, enhancing the User’s experience and personalizing the Service.
    • Additional Content you Choose to Share with us when using the Services
      • You may choose to upload to the Service User Content, such as images, text, reviews and report data gaps or errors, and other types of content which you actively choose to provide. We also collect your responses to surveys we may send you on our behalf or on behalf of our partners.
    • Third Parties
      • We may also collect personal information concerning you, from third parties who have assured us that they have obtained your consent for such provision of information or that you have freely and publicly provided. For example, we may collect and use demographic and other information that is publicly available in an applicable jurisdiction, additional contact information, credit check information, and information from credit bureaus, as allowed by applicable national laws.
    • Social Media you elected to connect to your account
      • We allow you to share information with social platforms, or use social platforms to create your Company account. These social platforms give us automatic access to certain personal information retained by these social networks about you. This includes your Facebook Access Token, Google Sign-In Token, advertiser ID and information from your public profile, which may include your name, gender, profile picture, age group and residency. You control the personal information you allow us to have access to through the privacy settings on the applicable social platforms and the permissions you give us when you grant us access to the personal information retained by the respective social platforms about you.
  2. HOW WE USE YOUR INFORMATION
    • Legal basis for use – We collect, process and use your information for the purposes described in this Privacy Notice, based at least on one of the following legal grounds:
    • When Performing this Agreement: We collect and process your personal information in order to provide you with the Service, following your acceptance of these Terms; to maintain and improve our Services; to develop new services and features for our Users; and to personalize the Service in order to deliver better user experience. For example, we collect your location information in order to provide you with recommended public transport means and routes to your destination.
    • With your consent: We ask for your agreement to process your information for additional specific purposes and you have the right to withdraw your consent at any time. For example, we ask for your consent to provide you with personalized content through the use of cookies;
    • Legitimate interests: We process your information for our, or our third parties, legitimate interests while applying appropriate safeguards that protect your privacy. This means that we process your information for things like detecting, preventing, or otherwise addressing fraud, abuse, security, usability, functionality or technical issues with our services; protecting against harm to the rights, property or safety of our properties, our users or the public as required or permitted by law; for the development and enhancement of our Services; for enforcing legal claims, including investigation of potential violations of this Privacy Notice; in order to comply and/or fulfil our obligation under applicable laws, regulations, guidelines, industry standards and contractual requirements, legal process, subpoena or governmental request, as well as our Terms of Service. Purpose of UseWe may use information that we collect about you for the following purposes:
    • to provide you with and to operate the Service, including for aggregation, statistical and research purposes and creation and use of aggregated anonymous data;
    • to personalize the Service and content provided to you, to customize your experience with the Services, to suggest you with transport recommendations based on your preferences and to enable you to retrieve your information;
    • to develop, improve and customize the Service, the experience of other users and the offering available through the Service;
    • to be able to contact Users for the purpose of providing them with technical assistance, support, handle requests and complaints, and collect feedback in connection with our performance of the Services and in connection with public transportation needs;
    • to send you updates, notices, announcements, and additional information related to the Service
    • to be able to reply to User online queries in connection with performance of the Services;
    • for customization and improvement of the Service’s accuracy and interface;
    • to display or send to you marketing and advertising material when you are using the Service, including in accordance with the section titled ‘Direct Marketing’ herein and
    • to comply with any governmental agencies’ legal requests or court orders, and/or with any applicable law, rule or regulation.
    • to use the information to create statistical, aggregated or anonymous data which may be used at our discretion for any purpose.
  3. TO WHOM WE SHARE PERSONAL INFORMATIONWe may share your personal information with third parties (or otherwise allow them access to it) only in the following manners and instances:
    • Third Party Services
      • The Company has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include Moovit App Global Ltd., hosting, database and server co-location services (such as AWS, RedisLabs), data and cyber security services (such as Reblaze), Payment Processors (such as BrainTree, Zooz), fraud detection and prevention services (such as Reblaze), data analytics services (such as Facebook Analytics, Google Analytics), App analytics tools including session replay records for usability and functionality monitoring and analysis (such as: Appsee, Crashlytics), services of measuring our Services attribution and effectivity of our publication and marketing efforts (such as: Appsflyer), e-mail distribution and monitoring services (such as Mailchimp, Mandrill), and our business, legal and financial advisors (collectively, “Third Party Services“). Such Third Party Services may receive or otherwise have access to our Users’ personal information, depending on each of their particular roles and purposes in facilitating and enhancing our Services and business, and may only use it for such purposes. The Company, as the controller of the information collected from its Users in connection with the use of the Services, remains responsible any personal information processing done by Third Party Services on its behalf, except for events outside of its reasonable control.
    • Governmental/Law Enforcement Agencies and Legal Requests or Duties
      • We may disclose or otherwise allow access to your personal information pursuant to a legal request, such as a subpoena, search warrant or court order, or in compliance with applicable laws, with or without notice to you, if we have a good faith belief that we are legally required to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, counter terrorist financing verification requirements, fraud, or other wrongdoing.
    • Protecting Rights and Safety
      • We may share your personal information with others, with or without notice to you, if we believe in good faith that this will help protect the rights, property or personal safety of the Company, any of our Users, or any member of the general public.
    • Company Subsidiaries and Affiliated Companies
      • We may share personal information internally within our family of companies, for the purposes described in this Privacy Notice. In addition, should the Company or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your personal information may be shared with the parties involved in such event.
  4. WHERE DO WE STORE USER’S PERSONAL INFORMATION
    • Information regarding the Users will be maintained, processed and stored by us and our authorized affiliates and service providers in Israel and Ireland, and as necessary, in secured cloud storage, provided by our third party service provider.
    • While the data protection laws in the above jurisdictions may be different than the laws of your residence or location, please know that we, our affiliates and our service providers that store or process your personal information on our behalf are each committed to keep it protected and secured, pursuant to this Privacy Notice and industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.
    • You hereby accept the place of storage and the transfer of information as described above.
  5. USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES
    • When you visit or interact with our Services, we or our authorized service providers may use cookies and other similar technologies to help provide you with a better, faster, and safer experience, and for advertising and marketing purposes. You can read our full Cookie Policy http://www.discovermyroute.com/cookies_policy for more information.
  6. SECURITY
    • We take great care in implementing and maintaining the security of the Company’s Service and its User’s personal information. The Company and our third party provider Moovit App Global Ltd. employ industry standard procedures and policies to ensure the safety of its Users’ personal information and prevent unauthorised access, disclosure and alteration of any such information. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centres, and information access authorization controls. We cannot, however, guarantee that unauthorized access will never occur.
  7. COMMUNICATIONS FROM THE COMPANY
    • Service Messages
      • The Company may contact you with information regarding our Services, or your use thereof. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, including changes to these Terms, transactions performed, payment issues, service maintenance, etc. You will not be able to opt-out of receiving such service messages.
    • Promotional and Surveys Messages
      • In addition to communications that are an inherent part of our Services, occasionally we may also use your contact information to contact and notify you about new services and special opportunities or promotions we think you will find valuable and may also contact you in connection with surveys we conduct with respect to our services or in connection with public transportation issues either on our own behalf or on behalf of our partners. We may contact you through e-mail, phone (including text messages), push notifications, through the Services, or any other contact methods available to us, including with the help of our Third Party Services.
      • Accordingly, we shall be entitled to call you or send you promotional content or messages by e-mail, SMS, direct text messages, web chat, marketing calls, and similar forms of communication.
      • If you wish not to receive such promotional messages or calls, you may notify the Company at any time by e-mailing us at dmr_support@cltoronto.ca, or by following the “unsubscribe” or “stop” instructions contained in the promotional communications you receive. As for messages we send through push notifications you may opt-out of receiving such notification by changing your device or App settings.
  8. YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
    • If you are an EU, EEA or Switzerland person and to the extent entitled under applicable law of your jurisdiction, you may contact us to exercise your right to access personal information, to request us to make corrections to your personal information that you have stored with us, to object to any form of processing, or to have such personal information deleted or exported in a portable copy. For this, please send us an e-mail to privacy@cltoronto.ca, or mail your request to the EU representative with a copy to Community Living Toronto, ATTN: Discover My Route Privacy, 20 Spadina Rd, Toronto, ON M5R 2S7, Canada, and we will respond within a reasonable timeframe and in accordance with applicable laws and regulations.
  9. HOW LONG MAY WE KEEP YOUR PERSONAL INFORMATION
    • We will retain your personal information for as long as you maintain an account or as otherwise necessary to provide you the Services. We will also retain your personal information as necessary to comply with our legal obligations, to resolve disputes, to prevent fraud and abuse, to enforce our agreements and/or protect our legitimate interests.
    • Where we no longer need to process your personal information for the purposes set out in this Privacy Notice, or following your request to delete your Personal Information, we will delete or anonymize your personal information from our systems.
  10. MINORS
    • To use our Services, you must be over the age of sixteen (16). Therefore, we do not knowingly collect personal information from minors under the age of sixteen (16) and do not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the Services.
  11. CHANGES TO THE PRIVACY NOTICE
    • The terms of this Privacy Notice will govern the use of the Service and any information collected therein. The Company reserves the right to change this notice at any time, so we encourage you to re-visit this page frequently. In the event of any substantial change of this notice, we will provide you with 7 days’ prior notice via any of the communication means available to us, or by posting notice of the change on the Site. After this 7-day notice period, all amendments to this Notice shall be deemed accepted and effective on both you and us. Except if and as stated otherwise, our most current Notice shall apply to all personal information described in such Notice.